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4) Did the Most Common Inspection Triggers between June 2004 and 2007 Influence Performance?

Most Common SQG Inspection Triggers

(June 2004 – June 2007)

  • “Routine” – with regular frequency, e.g., once every 2 years [None of the States]

  • Complaint [CO, MA, NH, VT]

  • Inspector Discretion [CO, MA]

  • Other:

    • CT Special Initiative to Inspect all SQGs

    • NH SQGs Who Failed to Become Certified

    • MA targets all SQGs that are a major air source and/or

major water source

    • Vermont has a policy to inspect once every 10 years

  • o

    The data do not appear to support a relationship between most common inspection triggers and the measured SQG performance.

5) Did Who Conducted SQG Compliance Inspection between June 2004 and June 2007 Influence Performance?

SQG “Compliance Inspections”

(June 2004 – June 2007)

Who Conducted What Unit?

SQG Inspections?

  • All states used compliance inspectors with the exception of CT.

  • Most states used their hazardous waste group to complete compliance inspections.

  • CT inspections were mostly conducted by interns. Compliance inspectors accompanied interns during the first several weeks for training, periodically throughout the initiative, and would also return to facilities to conduct full inspections when significant violations were found.

  • Other:

    • MA does not have a dedicated hazardous waste unit. Conducts primarily multi- media inspections and single media inspection for certain categories of sources

    • RI used Compliance & Inspections Unit which completes mostly RCRA inspections

Note: Staff who conducted the Common Measures field observations may or may not be the same staff noted above.

The States Common Measures Project Final Report


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